NIOSH Response to SC&A’s Review of the Linde Ceramics P

Exposure Cohort (SEC) Petition 00107 and the NIOSH SE

Evaluation Report, dated June 18, 2009. 

Prepared by 

NIOSH/Office of Compensation Analysis and Support 

and 

ORAU Team 

For 

Linde Working Group Meeting 

September 2, 2009 

Note: All comments keyed to “Table 1. Summary of Findings” on page 6 of SC&A documen

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Finding 1: The observation that data taken after 

decontamination of Building 31 were higher than before decontamination calls into question the quality of the radon measurements. This finding is supported by a statement made by the authors of Bechtel 1982 that the radon data from Building 31 were “unconfirmed,” again indicating concerns about data quality. 

While the scope of the decontamination performed between 1976 and 1981 is unknown, owing to the fORNL report described building 31 as having elevacontamination in "small isolated areas". This is costatement on page B-14, "The FB&DU survey team resurvey in 1981 in buildings 30, 31, 38 and a compBuildings 14 and 37, which were decontaminated b1980.” There is no basis for interpreting the statement that “unconfirmed” as an expression of the data quality. 

Finding 2: Use of the GM rather than the 95th percentile as the appropriate exposure metric needs to be justified for use in a bounding calculation, particularly since measurements taken in 1976 are used to characterize the entire residual period beginning in 1954. Use of 1976 data for a much earlier period needs to be justified by demonstration of equivalent (or less contaminated) radiological conditions. 

Comparison of 1954 and 1976 contact beta/gamma building 30 are not significantly different. The ave

measurements conducted in 1976 is 0.64 mrep/hr vaverage of 0.47 mrep/hr for the 1954 data. This is l

that most of the contamination was fixed. This is su

examination of Table 5 of ORNL 1978. 

Location area, ft2 dose rate, mshipping and receiving 9900 1.00 

Step 1 

Moore Area 5400 0.44 West Area 13500 0.39 East Area 11700 0.44 Tank and Compressor Room 1800 0.84 Main Balcony 13000 0.27 

Step 2 

Main 12000 0.33 Balcony 6000 0.48 

73300 Weighted A

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Finding 3: Use of measurements taken in 1981 to 

characterize radon exposures up to 28 years earlier may not be bounding. Use of such data needs to be technically justified. 

As stated in the response to finding 2, the radiologichange within this period. 

Finding 4: The NIOSH assumption that a single air sample taken in the 1970s can be used to bound plausible internal exposures to uranium, Th-230, and Ra-226 for over 50 years beginning in 1954 is highly questionable. 

As noted in finding 2, the radiological conditions d

this period. Note that if one were to apply a resuspto the 95th percentile of the fixed alpha readings (asfraction of 0.1), the resultant estimation of air activpCi/m3 as compared to the value of 0.019 applied i

Finding 5: NIOSH assumes that the GSD of the lognormal distribution is 5, when guidance in Battelle 2007 recommends a value of 10 for site-wide estimates. The placement of the single sample on the lognormal distribution could lead to substantial errors and cannot be reliably done. 

Owing to the fact that the ‘process’ involved is gen

that there are no process emissions occurring, the Gmore appropriate than the value of 10 cited for site-

Finding 6: NIOSH’s use of a constant air concentration, rather than an exponentially declining concentration, may be not be claimant favorable and is not consistent with the guidance in ORAUT-OTIB-0070. Back extrapolation needs to be technically justified by examination of potential site-specific changes in residual contamination. 

As stated in finding 2, no significant reduction in coevident. 

Finding 7: The process selected to establish the predecontamination dust level does not appear to be claimant favorable, based on the cited data source (Heatherton 1950). 

There is no reason to believe that the decontaminati

employed during building decon (concrete removal hammer, flame cleaning, and sandblasting) would brenovation. Additionally, as SC&A points out, the contamination levels during the step III decon were step I and II, on which the building renovation scen

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Finding 8: The assumed decontamination factor of 8 is 

based on pre- and post-decontamination values taken in different areas. Examination of the full dataset suggests that the differences in the potential internal exposures between the early and later decontamination activities may be negligible. 

Rather than attempting to reinterpret 50 year old da

use the summary data in Table IX, which representrepresentation of pre and post decontamination valudata in tables 1 and 2 are used directly, the weightedecontamination factor is 2. 

Finding 9: It is not clear that the bounding approach used in the SEC-00107 Petition Evaluation Report is more claimant favorable than that proposed in TBD-6001. 

The values contained in TBD-6001 are intended to 

be used when site specific data is not available, whi

Linde. 

Finding 10: The mix of alpha-emitting radionuclides in the airborne dust needs to be quantified for renovation activities, taking into consideration that raffinates might have been present. 

In practice, dose reconstruction would use Table 3-

accounts for uranium progeny.. 

Pre Decon Post Decon

contact, mrep/hr contact, mrep/hr

Step 1Moore 5400 0.44 0.33 

West 13500 0.39 0.11 

East 11700 0.44 0.4 

main balcon13000 y 0.27 0.1 

main 12000 0.33 0.4 

55600 Weighted Average 

Locaton Area, ft2 Pre/

Step 2

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cleared for distribution. 
NOTICE: This report has been reviewed to identify and redact any information that is protected by the Privacy Act 5 USC 5

cleared for distribution. 

Finding 11: NIOSH needs to explain how internal exposures should be apportioned among the various exposure scenarios. 

During the residual period, there are three broad exgeneral occupancy, the 1960’s renovation period, aremediation periods. Properly speaking, these are Tthan SEC issues. We now have bioassay and air sathe Bechtel FUSRAP work that could be worked in

(if there are claims for that period), perhaps when thaccommodate the information from the ER, a sectiobe placed noting it as “reserved”, alternatively, this evaluated to develop a more appropriate exposure m